Legislative Council Panel on Environmental AffairsControl of Indoor Air Pollution

Legislative Council Panel on Environmental Affairs
Control of Indoor Air Pollution

PURPOSE

1. This paper presents the findings and recommendations of the consultancy study commissioned by the Environmental Protection Department (EPD) on the indoor air pollution in offices and public places in Hong Kong, and proposes a framework and way forward for the control of indoor air pollution.

BACKGROUND

2. In the Second Review of the "1989 White Paper on Pollution in Hong Kong" in November 1993, the Government recognised the existence of potential health risk and problems associated with indoor air pollution. To address this issue, the EPD commissioned a consultancy study on "Indoor Air Pollution in Offices and Public Places" (the Study) in October 1995. A Steering Group, chaired by EPD, was formed to manage the consultancy study. Other members included representatives from the Planning, Environment and Lands Bureau, Architectural Services Department, Electrical and Mechanical Services Department, Labour Department, and Department of Health.
   
3. The Study aimed to characterise and quantify the indoor air pollution in office premises and selected public places in Hong Kong, assess the causes of the pollution problems, and recommend suitable control strategies. It comprised (a) questionnaire survey; (b) field sampling and analysis; (c) statistical analysis of the results; and (d) study on the practice of other countries. The Study was completed in September 1997. The Executive Summary of the Study is attached in Annex I.

FINDINGS OF THE STUDY AND PROPOSED CONTROL OPTIONS

4. The Study has found that indoor air pollution in Hong Kong is very similar to that of other developed countries. About one-third of the occupants surveyed were dissatisfied with the indoor air quality (IAQ) of their respective buildings. Their perception of indoor air quality was found to have significant correlation with the actual measurement results including temperature, humidity, air change per hour, and levels of major air pollutants. Occasional high levels of pollutants such as carbon dioxide which exceeded internationally accepted guidelines were measured in some offices and public places. They were mainly caused by high occupancy density and inadequate ventilation.
   
5. The Study recognised that the approach adopted so far to control indoor air quality in Hong Kong is through implementing a series of ordinances and regulations which spread over a number of government departments. These statutory provisions can indirectly exert some controls on indoor air quality such as establishing basic ventilation requirements, imposing import and/or sale ban on certain products, and specifying designated "no smoking area" etc. A summary of responsibilities of government departments relevant to indoor air quality is given in Table 3 of Annex I.
   
6. The Occupational Safety and Health Ordinance enforced by Labour Department covers all workplaces including office premises, however it only covers employees. Occupational Exposure Limits are adopted by Labour Department to protect the health of employees. Whilst certain public places like cinemas and restaurants are under licensing control of existing legislation, there is no specific legislation on the control of indoor air quality in such other public places as shopping mall, karaoke, and gymnasium etc. This means that there is no enforcement body to take up complaint cases of such nature in Hong Kong at present.
   
7. The Study recommended that a more comprehensive management scheme with different implementation options for further consideration, and an inter-departmental Indoor Air Quality Management Group should be set up to co-ordinate the development on the control of indoor air quality. In the interim, a draft Code of Practice has been prepared by the consultant. This gives a set of indoor air quality objectives and good practices, and should be adopted by the practising professional and building management to ensure acceptable indoor air quality. The Study also recommended that the provisions of certain existing regulations should be strengthened to address the issue of indoor air pollution by making reference to the Code of Practice.
   
8. The Study recommended that indoor air quality at residential premises should be controlled on a voluntary basis and the Government should initiate public education to bring the issue of indoor air quality to the attention of the general public.
   
9.

For office and public places, the Study has proposed 4 options for institutionalising the control of indoor air quality within the Administration :-

(a) Option A : Self-regulation;
   
(b) Option B : Making use of existing legislation and system;
   
(c) Option C : Enhancing existing legislation through amendments; and
   
(d) Option D : Developing a set of new legislation on indoor air pollution.

Other than Option D, the other options can be adopted in various combinations for implementation. The Study proposed that a more comprehensive mechanism to strengthen the control over indoor air pollution (i.e. Option D) may be warranted subject to the review of the situation by the Management Group in a period of 3 years.

   
10. The Study also recommended that institutions with susceptible groups including schools, hospitals and homes for the young, the aged and the sick should be further studied.

PROPOSED PRINCIPLES AND FRAMEWORK FOR THE CONTROL OF IAQ

Control Strategies

11. Based on the findings and the recommendations of the Study, and the views of Government departments and professional bodies, a more comprehensive mechanism to strengthen the control of indoor air quality will be developed. The programme will be initiated in a progressive manner, starting with those buildings and premises where existing legislation can be used to deal with indoor air quality. This progressive control will represent a mix of Options A to C as recommended by the Study.
   
12. It is considered that the control of indoor air quality should be based upon the principle of self-regulation, either through administrative or statutory means. This means that building owners will need to employ suitably qualified personnel to check and certify that the indoor air quality of their buildings or premises complies with the standards set out. This will avoid the need to establish a large team of public officers to carry out inspections and surveillance. Use can also be made of the existing legislative framework or amendment of the appropriate legislation where necessary to enhance indoor air quality.
   
13. The Administration will review the position and consider the need to broaden the scope or introduce a set of dedicated legislation on the control of indoor air quality three years after implementation of the indoor air quality programme.

Indoor Air Quality Objectives

14.

An important element for a proper indoor air quality programme is the adoption of a set of consistent indoor air quality standards by different departments and bureaux. These standards should be comparable to the international standards adopted by appropriate authorities. It is intended over the next year to develop a set of Indoor Air Quality Objectives for Hong Kong. A 3-Level approach is being considered:

  • Level 1 represents very good indoor air quality that a high class and comfortable building should have. This level should be comparable to the best available indoor air quality standards.
     
  • Level 2 represents the recommended indoor air quality standards that provide protection to the public at large including the very young, the aged and pregnant women.
     
  • Level 3 represents the indoor air quality required to protect workers and employees.

It is expected that the 3-level Indoor Air Quality Objectives will encourage building owners and property management to pursue the best standards, as the merits of having greater prestige and higher market value for their building will serve as a major incentive to achieve a higher standard.

Code of Practices

15. In addition to the proposed 3-level Indoor Air Quality Objectives, it is also necessary to provide a comprehensive Code of Practice to define and specify the procedures, measures and methodologies that should be followed to evaluate indoor air quality as well as to achieve the Indoor Air Quality Objectives. This Code of Practice will act as a guide for the public and as the reference document for public and private sector professionals. The Study has already prepared a set of draft Code of Practice for this purpose. The draft Code of Practice will be used as the basis for consultations early next year.

WAY FORWARD

16. The Government has already set up an inter-department Indoor Air Quality Management Group, chaired by the Planning, Environment and Lands Bureau and comprising relevant departments and bureaux, to co-ordinate the development on the control of indoor air quality. Subject to comments by members, the Government will proceed to consult the public, building management, relevant trade organisations and professional bodies on strengthening the existing programme or statutory provisions and on the draft Code of Practice to address the issue of indoor air pollution. Our aim is to formulate a comprehensive indoor air quality management programme for improving indoor air quality within 1999. To bring the issue of indoor air quality to the attention of the general public, the Government will launch a public education and publicity campaign to increase public awareness and understanding of the importance of indoor air quality.

ADVICE SOUGHT

17. Members are invited to note the findings and recommendations of the Study and to comment on the proposed way forward for the overall control of indoor air quality in Hong Kong as outlined above.

Planning, Environment and Lands Bureau
December 1998

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